Letters

The Netting of Swaps

Summary

SIFMA’s Asset Management Group (AMG), Investment Adviser Association, the Investment Company Institute (ICI), and the Managed Funds Association (MFA) provide comments to the Commodity Futures Trading Commission (CFTC) requesting  that the Division of Swap Dealer and Intermediary Oversight (DSIO) of the CFTC grant relief to permit sponsors of registered investment companies and privately offered investment funds to net certain uncleared swaps held by a fund when applying the net notional test in amended Regulation 4.5 or 4.13(a)(3).

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